First Circuit: Sending Form 1099-A Post-Chapter 7 Discharge Does Not Violate the Discharge Injunction

On December 14, 2016, the United States Court of Appeals for the First Circuit affirmed the New Hampshire Bankruptcy Court and District Courts' findings that a mortgage lender sending Internal Revenue Service Form 1099-A to a debtor/homeowner post-Chapter 7 discharge does not violate the discharge injunction. In the case at issue, Bates v. Foreclosure News